In a speech before the NYU Program on Corporate Compliance & Enforcement in early October, Deputy Attorney General Rod Rosenstein said he would be establishing a working group to, among other things, review the Justice Department’s FCPA Pilot Program, corporate investigation training programs, the Financial Fraud Enforcement Task Force’s role, and the Department’s corporate monitor program.
The program as it stands mandates that companies hire a third-party expert who analyzes the company’s operations and compliance program and offers tips on how to give both a facelift. This person is chosen by the DoJ from three company picks, and the company is then required to keep that person around for several years, which often means additional fees during any court settlements.
